Internal Revenue Bulletin: 2004-8
February 23, 2004
Table of Contents
Insurance companies; interest rate tables. Prevailing state assumed interest rates are provided for the determination of reserves under section 807 of the Code for contracts issued in 2003 and 2004. Rev. Rul. 92-19 supplemented in part.
Short sale; broker; transfer. This ruling provides guidance on whether the delivery of shares made to a broker in transferring a short sale position from one broker to another broker will (1) cause a short sale to be deemed consummated under regulations section 1.1233-1(a), and (2) cause a short-against-the-box transaction to cease to be covered by the transition rule of section 1259 of the Code.
Low-income housing credit; satisfactory bond; “bond factor” amounts for the period January through March 2004. This ruling announces the monthly bond factor amounts to be used by taxpayers who dispose of qualified low-income buildings or interests therein during the period January through March 2004.
Treatment of environmental remediation expenses under section 1341. This ruling holds that amounts paid or incurred in the current taxable year to remediate environmental contamination that occurred in prior taxable years do not qualify for treatment under section 1341 of the Code.
Treatment of environmental remediation expenses under section 263A. This ruling holds that amounts incurred to clean up land that a taxpayer contaminated with hazardous waste by the operation of a manufacturing plant must be included in inventory costs under section 263A of the Code. Rev. Ruls. 94-38 and 98-25 clarified. Rev. Proc. 2002-9 modified and amplified.
LIFO; price indexes; department stores. The December 2003 Bureau of Labor Statistics price indexes are accepted for use by department stores employing the retail inventory and last-in, first-out inventory methods for valuing inventories for tax years ended on, or with reference to, December 31, 2003.
Final regulations under section 42 of the Code amend current regulations that affect the order in which credits are allocated from the state housing credit ceiling under section 42(h)(3)(C) and the time for meeting the 10-percent basis requirement under sections 42(h)(1)(E) and (F). These regulations also amend current regulations under section 42 to facilitate the electronic filing of income tax returns.
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